A 2023 ACCA disciplinary decision relating to a member makes interesting reading.

The main complaint was that he had created a document falsely claiming that his AML policies had been in existence for five years, when in fact they had not.

An ACCA remote AML inspection in October 2020 concluded by seeking additional documents including the firm’s AML Policy and Procedures document.

The ACCA compliance officer asked for the original version of the AML policy allegedly created in October 2018. The member claimed no updates had been made to the document and said that after reviewing the firm’s AML policy there was no need to make any changes to it.

At the subsequent disciplinary tribunal, the ACCA Case Officer pointed out that the AML Policy and Procedures document could not have been created in October 2018 because it was based on and ACCA technical factsheet “Anti-Money Laundering (AML) Policy and Procedures”, published by ACCA in February 2020.

The member eventually admitted that he had acted dishonestly when he claimed the AML policy had been in place since October 2018.

AML breaches

The AML Policy and Procedures created by the member had the following deficiencies:

There was a lack of evidence of:

  • A Firm-Wide Risk Assessment;
  • AML training to relevant staff;
  • The firm’s criteria for different risk ratings.

There were also problems with:

  • Inconsistency in the firm’s application of its AML Policy and Procedures Manual, because some clients had been incorrectly assessed as ‘medium risk’ when they displayed characteristics of one of more of the ‘high-risk’ factors listed in the firm’s AML Policy and Procedures document
  • Lack of evidence of AML training for staff;
  • The simple ‘Yes’/’No’ template used didn’t provide an assessment of the risks the firm faced or the actions to take to mitigate those risks;
  • The AML template document did to relate to relevant AML processes operated by the firm and had few details of the firm’s day-to-day processes.

 The disciplinary committee decided that Hung’s dishonesty and AML breaches reached the highest threshold of sanctions and excluded him from membership of the ACCA and he was ordered to pay costs of £6,000.

To hear more about the latest AML developments and how to be on the alert for suspicions of money laundering and terrorist financing under the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021, see our latest Anti-Money Laundering webinar here.

All our courses are listed here.

Please also go to our website to see our:

  • Anti-Money Laundering Policies Controls & Procedures Manual (March 2022) – View the Table of Contents click here.
  • AML Webinar (December 2023) available here, which accompanies the AML Manual. It explains the latest legal AML reporting position for accountancy firms and includes a quiz. Upon completion, you receive a CPD Certificate of attendance in your inbox.
  • letters of engagement and similar templates. Please visit our site here where immediate downloads are available in Word format. A bulk discount is available for orders of five or more items if bought together.
  • ISQM TOOLKIT or if you prefer to chat through the different audit risks and potential appropriate responses presented by this new standard, please contact John McCarthy FCA by e-mail at john@jmcc.ie.


  • We typically tailor ISQM training and brainstorming sessions to suit your firm’s unique requirements. The ISQM TOOLKIT 2022 is available to purchase here.